G.R. No. 219340 - Commissioner of Internal Revenue vs. Standard Insurance Co., Inc.

Antecedent Facts
Petitioner Commissioner of Internal Revenue (CIR) is head of the Bureau of Internal Revenue, tasked with assessing and collecting national internal revenue taxes.
Respondent Standard Insurance Co., Inc. is a domestic non-life insurance corporation.
On February 13, 2014, the BIR issued a Preliminary Assessment Notice (PAN) for documentary stamp tax (DST) deficiency for taxable year 2011 in the amount of ₱377,038,679.55; respondent contested but eventually received a Final Decision on Disputed Assessment (FDDA) dated November 25, 2014, fixing its liability at ₱418,830,567.46.
Respondent also received demands for deficiency income tax, VAT, premium tax, expanded withholding tax and fringe benefit tax for taxable year 2012, and a DST deficiency demand for 2013, all protested on equal-protection grounds vis-à-vis Sections 108 and 184 of the National Internal Revenue Code (NIRC).

Regional Trial Court (RTC) Proceedings
December 19, 2014: Standard Insurance filed a Petition for Declaratory Relief in RTC Branch 66, Makati City, praying for a TRO and WPI to enjoin the CIR from enforcing NIRC Sections 108 and 184 pending resolution of the petition and pending enactment of House Bill 3235.
December 23, 2014: RTC issued a TRO enjoining implementation of the disputed provisions against respondent for taxable years 2011–2013; January 13, 2015: RTC granted WPI upon bond; February 18, 2015: RTC denied CIR’s motions to dismiss, for reconsideration, and to declare respondent in default.
May 8, 2015: RTC rendered a Decision permanently enjoining CIR from enforcing Sections 108 and 184 against Standard Insurance until Congress passed HB 3235; July 10, 2015: RTC denied CIR’s motion for reconsideration.

Court of Appeals (CA) and Supreme Court (SC) Proceedings
April 27, 2015: CIR filed a Petition for Certiorari (Rule 65) in the CA (CA-G.R. SP No. 140403) to set aside the interlocutory WPI orders; October 30, 2015: CA dismissed the petition for failure to comply with procedural directives.
September 7, 2015: CIR filed a Petition for Review on Certiorari (Rule 45) in the SC assailing the May 8, 2015 RTC Decision and July 10, 2015 Order on four grounds: applicability of declaratory relief, equal-protection clause, prohibition of injunctions under Section 218 NIRC, and scope of declaratory relief.
November 7, 2018: SC rendered its Decision granting CIR’s petition, annulled and set aside the RTC Decision and Order, dismissed Civil Case No. 14-1330 for lack of jurisdiction, quashed the WPI, and ordered respondent to pay costs.
Standard Insurance moved for reconsideration before the SC, arguing forum shopping, factual issues, RTC jurisdiction, compliance with Rule 63, and equal-protection rights.

Forum Shopping and Certification
Whether CIR’s petition must be dismissed for forum shopping.
Whether CIR failed to comply with the certification against forum shopping requirement.

RTC Jurisdiction for Declaratory Relief and Injunction
Whether the RTC had jurisdiction to entertain a petition for declaratory relief challenging tax assessments.
Whether the RTC could validly issue injunctive relief against Sections 108 and 184 of the NIRC.

Requisites of Declaratory Relief
Whether respondent’s petition satisfied the essential requisites under Rule 63 of the Rules of Court.